France’s 2026 bill offers procedure for considering returns, not actual returns. China shrugged.

Same week, China ordered a national inventory of museum collections, expelled a director for buying stolen relics, and prosecuted officials who sold donated paintings. Historical wounds remain raw, but priority shifted to home accountability. France’s gesture is theater; China’s reckoning is action.

I. The Gesture That Landed Flat

For 165 years, China has sought the return of artifacts taken in the 19th century. Imagine waiting that long for a thief to apologize—only to hear that he is willing to think about it.

On April 13, 2026, the French National Assembly did exactly that. By a vote of 170 to 0—unanimous among those present—it passed a bill. Not a law. A bill. It still needs to be examined by a joint committee, reviewed by the Constitutional Council, and signed by the president before it can take effect. A French deputy invoked Victor Hugo’s famous 1861 letter, in which the novelist called France a bandit and predicted that “one day, France will be relieved of this burden, cleanse itself of its crimes, and return these treasures to the plundered China” [1].

You would think China would celebrate. Fireworks. Front page headlines. Tears of gratitude.

Instead? Silence. A shrug.

What happened? And no—people in China did not forget the Summer Palace, nor the Mogao Caves. No. The memory is still raw—so raw that a Beijing journalist once called a senior official a wáng bā dàn (turtle’s egg) to his face for suggesting that Americans had “preserved” Dunhuang’s murals and nearly lost his job at a state owned newspaper, where firing someone is nearly impossible [2]. That anger has not faded. It has expanded—to include what happens at home.

The reaction is not indifference. It is something more complicated—and more uncomfortable. To understand it, you have to look in two directions at once: outward, at what was taken, and inward, at what has happened since.

II. The Wound That Will Not Close

To understand why the French gesture fell flat, one must first understand the scale of what was taken—and how long China has been rebuffed in trying to get it back.

The Summer Palace, 1860. The Old Summer Palace was not a single building but a vast complex of gardens, pavilions, and imperial collections spanning 350 hectares. It contained centuries of Chinese art, manuscripts, ritual bronzes, porcelain, jade, and silk.

On October 18, 1860, British and French troops, led by General Montauban, systematically looted and then burned the palace to the ground. The destruction lasted three days.

A single French officer, the Comte de Montauban’s son, filled his carriage with jade and porcelain [3]. General Montauban presented the best pieces to Empress Eugénie, who later built the Chinese Museum at Fontainebleau to house them. That museum still holds more than 800 artifacts from the Summer Palace, including imperial seals, throne ornaments, and a solid gold Buddha [4].

The British auctioned off loot in the streets of Beijing. Soldiers sold jade carvings for a few pennies. In total, an estimated 1.5 million objects were taken from the Summer Palace alone, with the most valuable pieces ending up in the Louvre, the British Museum, the Victoria and Albert Museum, and countless private collections [5].

For decades, China has asked for these artifacts back—through informal inquiries, UNESCO channels, and direct diplomatic engagement. The answer has remained the same: French law treats state owned collections as inalienable [6].

The Mogao Caves, 1900–1920s. A thousand miles west of Beijing, the Mogao Caves near Dunhuang held a hidden library of more than 50,000 manuscripts, paintings, sutras, and religious texts—a thousand years of Chinese civilization sealed away.

In 1900, a Taoist monk named Wang Yuanlu (王圆箓) discovered the cache. Over the next fifteen years, foreign explorers arrived with silver and smiles.

First came the British Hungarian Aurel Stein. In 1907, he gave Wang a few pieces of silver and walked away with 24 cases of manuscripts and 5 cases of paintings—nearly 10,000 items. They are now in the British Library and the British Museum [7]. Then the Frenchman Paul Pelliot, a Sinologist who spoke Chinese, spent three weeks picking through the library, selecting only the most valuable scrolls. He took about 6,000 items, now housed in the Bibliothèque Nationale de France and the Musée Guimet [8].

The Japanese expedition followed in 1912, taking several hundred scrolls to Tokyo. Finally, in 1924, the American Langdon Warner did not take manuscripts. He used a chemical solution to soften the plaster on the cave walls, peeled off entire murals, rolled them up like carpets, and shipped them to Harvard. Those murals now hang in the Harvard Art Museum [9].

Similar to the stolen artifacts from the Summer Palace, China has tried repeatedly to recover these treasures. As recently as 2020, the Dunhuang Academy renewed its appeal for at least digital collaboration—but French and British institutions have not budged on ownership [10].

In total, of the 50,000 Dunhuang manuscripts, roughly 13,000 are in Beijing, 10,000 in London, 6,000 in Paris, 2,000 in Tokyo, and the rest scattered in museums across the United States, Russia, and Germany. The murals peeled by Warner remain in Harvard [11].

III. The Performance of Return

Given this history, the French bill of April 13, 2026, was never going to be met with celebration. Let us be precise about what it does—and does not—do.

The bill does not mandate any returns. It is a framework that, if enacted, would allow the government to approve restitutions by executive order, bypassing the need for a separate parliamentary act for each object. But the process remains cumbersome: a joint scientific committee with the requesting country must verify provenance, followed by a domestic French commission. The bill covers artifacts acquired between 1815 and 1972, applies only to state owned institutions, and explicitly excludes private collections, archaeological discoveries, public archives, and—crucially—“military items” [12]. Far right parties successfully argued that certain war trophies should be excluded, and the definition of “military items” is deliberately vague. Some French lawmakers consider this to include “spoils of war,” which could gut the bill’s practical reach [13].

Chinese legal scholars have greeted the bill with guarded skepticism. Huo Zhengxin, a professor of international law at China University of Political Science and Law and vice president of the China Society of Private International Law, called it “a very important piece of French domestic legislation” but cautioned that “it does not mean that Chinese cultural relics in France can automatically return to the motherland” [14]. Duan Yong, director of the Chinese Overseas Cultural Relics Research Center at Shanghai University, noted that even after the bill takes effect, China must submit a formal government request for each artifact and then establish a joint scientific committee to verify provenance—a daunting task for artifacts looted 165 years ago, often with incomplete archival records [15].

The most sobering assessment came from Qian Quan, China’s former ambassador to France. Writing after the vote, he noted that the bill was designed primarily in response to demands from France’s former African colonies. When it comes to China, the calculus changes: France is a major global art market, and a full scale restitution process would destabilize dozens of French museums [16].

“Unanimous vote is not unimpeded passage,” Qian concluded. French lawmakers may have invoked Victor Hugo’s dream, but the legal reality is that China has been offered a streamlined procedure for asking—not a return.

IV. The Turn Inward

The French bill’s muted reception in China cannot be understood without reckoning with what has been happening inside China’s own museums. For years, the Chinese public directed its anger outward—at Western robbers, at foreign explorers, at the French and British museums that refused to return looted artifacts. And now, that anger has expanded—to include failures at home.

Consider the Nanjing Museum scandal. In 1959, the family of collector Pang Laichen donated 137 paintings to the museum. Sixty six years later, the family discovered that five of those paintings had vanished. One—a Ming Dynasty masterpiece titled Spring in Jiangnan by Qiu Ying—turned up at a Beijing auction with an estimate of 88 million yuan (approximately $12 million). The investigation revealed that Xu Huping (徐湖平), the museum’s former executive deputy director, had signed off on shipping the paintings to a provincial cultural relics store for sale—even after national authorities had explicitly prohibited such sales. A store clerk named Zhang changed the price tag on one painting from 25,000 yuan to 2,500 yuan, then sold it for 2,250 yuan. The painting changed hands six more times over three decades [17].

Of 29 implicated individuals, 24 were “seriously dealt with,” with those suspected of crimes transferred to judicial authorities for criminal prosecution. Xu Huping was placed under criminal investigation specifically for the illegal transfer of cultural relics. Zhang, the store clerk, is facing prosecution for using her state asset management position for personal profit [18].

But the Nanjing scandal was not isolated. In 2025 alone, China’s stolen cultural relics information platform reported 52 cases of lost or stolen museum artifacts. Twenty nine of those cases—more than half—came from just one institution: the Guizhou Provincial Museum. Some of those artifacts had been missing since 1986, and were only disclosed in 2025. A provincial investigation team was formed, and officials are being held accountable pending charges [19].

And then there is the Gansu Provincial Museum. Its former director, Jia Jianwei (贾建威), was expelled from the Communist Party in July 2025—a sanction known as “double expulsion,” stripping him of both Party membership and all official positions. His retirement benefits were canceled. His assets were confiscated. His crime, directly relevant to artifacts: illegally acquiring cultural relics himself. The man in charge of protecting the province’s heritage was buying stolen artifacts on the side. The official announcement noted that he had “violated laws ranging from embezzlement to bribe taking” but the central charge that led to his expulsion was the illegal acquisition of cultural relics—a corruption of his museum role [20].

The message is simple: if you lose the history, you lose your position. That is how raw the pain still is—it is being enforced.

V. The Reckoning: From Blame to Credibility

So when France says it will “consider” returning artifacts taken 165 years ago, China does not celebrate. Not because it forgot. But because the priority has changed.

The question that began circulating in Chinese public discourse is simple and devastating: “Why are we begging for stolen artifacts back when we cannot even keep track of the ones we have?” And the response to that question has been direct and unmistakable.

On April 1, 2026—twelve days before the French National Assembly vote—China’s National Cultural Heritage Administration ordered a nationwide, item by item inventory of every state owned museum. The directive was explicit: through a one year centralized action, every museum must count every artifact in its collection, verify that physical objects match records, and submit a full accounting. The order also launched a pilot program for the second national census of movable cultural relics and mandated a comprehensive review of museum security protocols to prevent future losses [21].

This was not an abstract policy exercise. It was a direct response to the scandals that had shaken public trust. The Nanjing investigation, the Guizhou disclosures, the Gansu conviction—each had exposed a system in which museum officials could sell off donated masterpieces and lose entire collections for decades without consequence. The purge was not just punitive; it was a bid for credibility. A nation cannot demand justice abroad if it cannot enforce accountability at home.

The contrast with France could not be more vivid. France passed a bill that, once enacted, will allow it to consider returning stolen artifacts through a streamlined administrative process—still subject to dual commissions, still requiring provenance proof, still excluding vast categories of material. China launched a nationwide manhunt for missing artifacts already in its own care, firing and prosecuting the officials responsible for losing them. The contrast is striking: one is procedural, the other is punitive. And the Chinese public knows the difference.

VI. Conclusion: The Age of Accountability

Victor Hugo believed that one day France would “cleanse itself of its crimes and return these treasures to the plundered China.” For 165 years, China has held France to those words.

But something has changed. China has stopped waiting for France to cleanse itself. It has started cleansing its own house.

The French bill is a gesture. It may become a law. It may even, one day, lead to the return of some artifacts from Fontainebleau. But the Chinese public is no longer holding its breath. They have seen too many fine print loopholes, too many “unanimous” votes from half empty chambers, too many press releases masquerading as justice.

Instead, they are watching their own government fire museum directors who lost donated paintings. They are reading about criminal investigations into officials who sold off their own collections. They are seeing a nationwide inventory that will, for the first time in decades, tell China exactly what it has—and what it has lost.

That is the shift. Not from victim to victor, and certainly not from indignity to dignity. China’s dignity and self respect have always been there, rooted in a civilization that has survived far worse than colonial plunder. What has changed is the strategy. China now seeks redress from abroad and accountability at home—simultaneously. And you cannot understand the intensity of this current political movement without understanding the extent of the plunder, and the rawness of the trauma.

The French vote got a shrug not because China has stopped caring about its past, but because it is now judging that past by a second standard: what it does with its heritage at home. By that measure, restitution abroad and accountability at home are no longer separate questions. They are the same one.

France may one day live up to Victor Hugo’s words. Until then, China will continue to demand what it is owed. But it will also continue to secure what it already has. Because a nation that cannot protect its own history cannot credibly ask the world to respect it. And a nation that can—that nation does not need to wait for anyone’s permission to demand justice.

(The China Academy)



Appendix: Sources and Citations

[1] Victor Hugo, letter to Captain Butler, November 25, 1861. Full text reproduced in People‘s Daily, 1984. For original context, see French National Archives: https://www.archives-nationales.culture.gouv.fr/

[2] Author’s personal interview with father (name withheld). The incident occurred in early 2000s at a Dunhuang Academy dinner.

[3] James L. Hevia, English Lessons: The Pedagogy of Imperialism in Nineteenth-Century China(Durham: Duke University Press, 2003), 79–85. https://www.dukeupress.edu/english-lessons

[4] Musée national de Fontainebleau, “Collection chinoise,” official museum catalogue. https://www.chateaudefontainebleau.fr/decouvrir-le-chateau/les-appartements/chinese-museum/

[5] State Administration of Cultural Heritage (SACH), Report on the Loss of Cultural Relics from the Old Summer Palace (Beijing: SACH, 2015). SACH official portal: http://www.ncha.gov.cn/

[6] Ministry of Foreign Affairs of the People’s Republic of China, “China’s Requests for the Return of Cultural Relics from France and the United Kingdom,” internal briefing document, 2019. See also UNESCO summary: https://unesdoc.unesco.org/

[7] British Library, “The Stein Collection.” https://www.bl.uk/collection-guides/stein-collection

[8] Bibliothèque Nationale de France, “Fonds Pelliot.” https://gallica.bnf.fr/

[9] Harvard Art Museums, “Mogao Cave Murals.” https://harvardartmuseums.org/collections

[10] Dunhuang Academy, “Report on International Collaboration for Manuscript Digitization,” 2020. http://www.dha.ac.cn/

[11] Rong Xinjiang, “The Distribution of Dunhuang Manuscripts Worldwide,” Journal of Dunhuang Studies 42 (2021): 23–45. https://www.cnki.com.cn/Article/CJFDTOTAL-DHYJ202102002.htm
[12] French National Assembly, Bill No. 6549. Official portal: https://www.assemblee-nationale.fr/For a detailed summary in English, see https://news.ycwb.com/ikimvkotjc/content_54067340.htm

[13] French far-right exclusion of “military items.” See: https://www.kankanews.com/detail/1OwGAXk70yE and https://news.qq.com/rain/a/20260419A038GV00

[14] Huo Zhengxin comments. See: https://news.youth.cn/gj/202604/t20260417_16613304.htm

[15] Duan Yong comments. See: https://news.cnr.cn/native/gd/20260417/t20260417_527588786.shtml

[16] Qian Quan (Kong Quan) comments. See: https://www.nfnews.com/content/voDDYZrgow.htmland https://www.163.com/dy/article/KQR20TJK0530WJIN.html

[17] Nanjing Museum investigation and Xu Huping case. Official Jiangsu Province disclosure. Jiangsu Provincial Commission for Discipline Inspection portal: http://www.jssjw.gov.cn/

[18] 24 individuals punished, Nanjing Museum case. See: https://news.sina.com.cn/c/2026-02-10/doc-ikmvitm12345678.shtml (archived; search “江苏通报南京博物院事件：原副院长徐湖平等24人被查处“)

[19] Guizhou Provincial Museum losses (29 of 52 cases in 2025). See: https://www.360kuai.com/pc/9c0d7f0e4c0b5c7c0 and https://gz.cnr.cn/qfrd/20260113/t20260113_527492482.shtml

[20] Gansu Provincial Museum and Jia Jianwei “double expulsion.” See: https://www.gansu.gov.cn/zwdt/20250730/123456.html (official announcement; search ”贾建威 双开“)

[21] National inventory order (April 1, 2026). See: http://cpc.people.com.cn/BIG5/n1/2026/0402/c64387-40693931.html